As pointed in my previous blog post the hearing in the IRS effort to enforce its John Doe Summons in the UBS Offshore Bank Account case had been delayed by mutual agreement with a status conference to be held on Wednesday, June 29th. According to an article by Tom Brown published by Reuters, at the status conference the parties announced that no settlement had been reached in the highly watched case in which the Internal Revenue Service seeks to obtain the names of 52,000 UBS offshore account holders who the IRS believes may have committed tax evasion, and who probably failed to file foreign bank account reports (FBARs). Judge Gold, the federal district court judge presiding over the case stated that “absent a signed settlement agreement” no requests for delay would be considered, and that trial of the UBS case would proceed to trial on Monday, August 3rd.
If you have a Swiss financial account, or an offshore account outside the United States, now is the time to consult with a tax attorney to find out whether or not you should make a voluntary disclosure, and participate in the IRS tax amnesty program.
If you have further questions, feel free to arrange a consultation with the tax litigation attorneys at Brager Tax Law Group, A P.C.